THE NEW DOUBLE TAX AGREEMENT BETWEEN SOUTH AFRICA AND MAURITIUS – WHAT IS THE EFFECT ON BUSINESS?

The news of the revised double tax agreement between South Africa and Mauritius (“the new DTA”) on Monday, 27 May, rang alarm bells for both Mauritian companies investing into South Africa as well as for South African companies expanding offshore via Mauritius. What are these changes and how will they impact on the use of Mauritian companies for investment by non-residents into South Africa, or for foreign investment by South Africans?